ML20101C829
| ML20101C829 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/21/1984 |
| From: | Morgan R CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20101C832 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 RSEP-84-434, NUDOCS 8412210214 | |
| Download: ML20101C829 (5) | |
Text
,
_3 -
e csm Carolina Power & Light Company RC JUN 27 P l : l2 H. B. ROBINSON STEAM ELECTRIC FL/RT POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550 JUN 211984 Robinson File No:
13510E Serial: RSEP/84-434 Mr. James P. O'Reilly Regional Administrator Region II' U. S. Nuclear Regulatory Commission 101 Marietta Street, N. W.
Atlanta, Georgia 30323 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 LICENSEE NO. DPR-23 IE INSPECTION REPORT 84-10
Dear Mr. ('Reilly:
Carolina Power and Light Company has received and reviewed the subject report and provides the following response.
A.
Severity Level IV Violation (IER-84-10-01-SL4) 10CFR20.203(b) requires that each radiation area be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words:
Caution (or Danger), Radiation Area.
Contrary to the above, the licensee failed to post a radiation area in that on March 23, 1984, a trailer containing fuel sipping equipment with general area radiation levels around the trailer measuring 8 mR/hr was not posted as a radiation area.
Response
l 1.
Admission or Denial of the Alleged Violation CP&L acknowledges the alleged violation.
8412210214 840621 PDR ADOCK 05000261 G
PDR i
TEof>
i+ Lsttsr to Mr. J:mes P.~0'Railly, S2 rial:; RSEP/84-434-Page 2 of:S 2.
Reason f5r the' Violation The' subject trailer had arrived on site as a radioactive waste shipment and was properly placarded in accordance with DOT regulations. The radiation level 18" from the surface of the trailer was as high as 8 mR/hr. Initial interpretation of 10CFR20.204(d) determined that the trailer could go unposted as a radiation area since it was still placarded in accordance with DOT regulations with the appropriate "RADI0 ACTIVE". placards. After subsequent review of 10CFR20.204(d), it'is agreed that this only applies to.those materials that have been prepared for transporr in accordance with DOT regulations. The'cause of this
. violation was a misinterpretation'and misapplication of the provisions of-10CFR20.204(d).
3.
Corrective Steps Which Have Been Taken Upon notification of the violation, the subject trailer was posted as' a RADIATION AREA" as prescribed by 10CFR20.
- 4.
Corrective Steps Which Will Be Taken Radioactive materials receipt procedure will be revised to ensure that
- 10CFR20.204(d) is not misapplied in the future.
In addition, the-appropriate Radiation Control personnel will be traired on the revision.
5.'
Date When Full Compliance Will Be Achieved The corrective actions are-scheduled to be completed by August 15, 1984.
B.
Severity Level Violation IV (IER-84-10-02-SL4)
- 10CFR20.203(f) requires that each container of licensed material shall bear a durable, clearly visible label identifying the radioactive contents. The exceptions of 10CFR20.203(f)(3) do not apply.
Contrary to the above, the licensee failed to label a container of e
radioactive material in that on March 20, 1984, a metal box utilized for
- holding laundered protective clothing was not labeled with a clearly
- visible label identifying the radioactive contents of the box.
Response
1.
Admission Or Denial Of The Alleged Violation CP&L acknowledges the violation in part. CP&L disagrees with the statement that the exceptions of 10CFR20.203(f)(3) do not apply.
If it could be substantiated that the contents of the subject boxes did satisfy one of the exceptions provided for by 10CFR20.203(f)(3), no violation
- would have occurred. Since it has not been substantiated that a said
-exception was applicable in this instance, CP&L acknowledges that a violation occurred.
I
~
A-v w
-ms
,e.
,m s,
-r,~-e,n,en,-.,, -,.---,snv,--.-,,wn v,v -, w e n n&m.
,.-,r-~
e,.,,,--n.
w.
~. ww n n-wp~,,v.n.,,-
,n,.
v sv---~
m.
~
i Lcttsr-to Mr. Jnaam P. O'Railly S2ric1 RSEP/84-434 Page 3 of 5 2.
Reason For The Violation The subject boxes contained laundered protective clothing and were posted as " RADIOACTIVE MATERIALS". The postings were weathered to the point that they were no longer clearly visible.
3.
Corrective Steps Which Have Been Taken Upon notification af the violation, the subject boxes were labeled as "RADI0 ACTIVE MATERIAL" as prescribed by 10CFR20.
In addition, surveillance by Radiation Control personnel and supervision as well as Plant Quality Assurance personnel has been increased to ensure that other containers that may contain radioactive materials are properly labeled as prescribed by 10CFR20.
I 4.
Corrective Steps Which Will Be Taken The corrective actions taken are considered adequate to avoid further violations of this nature.
J) 5.
Completion Date Full compliance has been achieved.
C.
Severity Level IV Violaton (IER-84-10-03-SL4)
)10CFR20.103(c)(2)requirescertainconditionstobemetbeforealicensee may make allowances for the use of respiratory protective equipment.
One condition is that the licensee maintains and implements a respiratory protection program that includes written procedures regarding training of personnel. Health Physics Procedure HPP-102, Respirator Fit-Testing, Section 5.2.2 requires that personnel attend a respiratory training class and pass a test prior to wearing a respirator.
Contrary to the above, during 1983, fifteen licensee personnel wore respirators without first passing a written test.
1.
Admission Or Denial Of Alleged Violation CP&L acknowledges the alleged violation.
2.
Reason For The Violation Plant procedures require a passing grade on a respiratory protection test
_ prior to wearing a respirator. A surveillance was conducted on March 14
- 16,_1984, by H. B. Robinson Plant Quality Assurance personnel in the area of respiratory protection. This surveillance included a review of the grading techniques and grades received on the respiratory protection tests. Several tests which were given and graded by a specific contract instructor were found to be graded improperly. The test results of the 581 individuals trained by this specific instructor were checked. Of this number, 51% were found to have been graded improperly. The tests were then regraded which yielded a 24% failure rate out of the original 581.
L
n
.Littsr to Mr.'Jrmes P.'O'Railly Ssrials, RSEP/84-434 I
Page.4'of 5
.]
m An investigation was ade into.the grading tec$niques of other instructors. The-original sample of 581 was used to determine the appropriate sample (lot) size. Using the sampling tables of Military-SID-105D, which correspond to Enclosure 2'of the Quality; Assurance Procedure-205,= a sample size of 30 was determined. The-test records ~of 80 random individuals were regraded.. The results are that.12 grades.were' lowered, with 4 of these 12 being. failures..:That is to say that only 5% of the randomly selected 80 test scores were. actual failures. The 4 individuals identified have also been removed from the qualification list. : This investigation shows that the high percent of failures was associated with one-instructor.
These results have shown that the deficiency lies in the type of esting.;
The tests had essay type questions, and grading was therefore su
)ctive-which in turn led to inconsist'ent and inaccurate grading.
3.
Corrective Steps Which Have Been Taken Immediate action to correct the problem was taken on March 16,1981.Oy removingthenamesof,allpersonnelknowntohavefailedthetest[Irom the computer listing of qualified personnel for respiratory protection.
Any of these individuals who are currently wearing respiratory protection devices have been appropriately requalified.
'An investigation into the resulting whole body counts of the individuals who failed the respiratory protect. ion test was conducted. Of the individuals who received a terminating whole body count, an upward trend was not identified, and no unusual or excessive-body burdena were identified.
A set of objective tests, i.e., multiple choice, true/ false. etc. with-answer keys has been developed and are currently in use so'that there will be no subjectivity involved.
4.
Corrective Steps Which Will Be Taken
\\
The corrective actions taken are considered adequate to avoid ft5rther violations of this nature.
5..
Completion Date 1
i' Full compliance has been, achieved.
h l
The.following response is submitted as requested in the inspection' report cover letter. NRC Inspection Report 84-10 discusses a submittal'ro the Director of Nuclear Reactor Regufation which contained inaccurate statements.
While the statements were not material or relevant to thi decision made, a concern was expressed that these inaccuracies were not eliminated during the review process.
A process has been implemented to ensure a complete review of outgoing
-correspondence. This should minimize the potential for future inaccurate i
statements from occurring.
l 1
e
1
., '-..e-
- Lsttsr.to -Mr. J:mes P. O'Reilly Ssrinl:.RSEP/84-434 Page 5 of'5 If you have any questions concerning this response, please contact my staff or me.
Very truly yours.
WW R. E.
o
- an Genera ager H. B. Robinson'S. E. Plant CLW
- pb cc:
R. C. DeYoung t
b
-